At-Home Covid Tests to be Covered by Health Insurance Carriers and Group Health Plans

Considering the brief timeframe, Caravus will be closely monitoring updates from health insurance carriers regarding how they will implement this new regulation.

Beginning Saturday, January 15, 2022, FDA approved over the counter (OTC) at-home Covid-19 tests are required to be covered by health insurance carriers and group health plans without member cost sharing, preauthorization, or provision by a health care provider.  

The new coverage requirement for OTC Covid-19 testing comes from an FAQ document released by The Department of Labor (DOL) and Health and Human Services (HHS) to clarify the statement issued by the White House on December 2, 2021, stating OTC Covid-19 testing would be provided at no cost.  

 Click Here for the DOL & HHS FAQ 

 Click Here for the White House Statement

Prior to January 15, 2022, mandates under The FCCRA and CARES Act stated health insurance carriers and group health plans were only required to cover FDA approved Covid-19 testing without member cost share or preauthorization if the tests were managed by a health care provider. The new coverage requirement for OTC testing is an addition to the FCCRA and CARES Act Covid-19 testing mandates mentioned above. All previous legislation remains intact and unchanged.  

Implementation Overview  

Health insurance carriers and group health plans can take the “direct coverage” path by purchasing the tests from sellers and manufacturers upfront so covered members can obtain their OTC Covid-19 tests via in-network pharmacies or retailers.  

 If the “direct coverage” approach is taken, a safeguard could be enacted in the event a covered member purchases OCT testing through an out-of-network pharmacy or retailor. The health insurance carrier or group health plan would only be responsible for reimbursing the member up to $12 per test.  

 Instead of the “direct path method”, private health insurance carriers and group health plans can require covered members to pay for OTC testing at the point of sale then submit a request for reimbursement. 

 If reimbursement submission is required, the insurance carrier or group health plan must reimburse the member fully, regardless of the OTC test price, which could be over $12.  

Quantity & Regulation Overview 

Each member covered through a health insurance carrier or group health plan is granted eight OTC Covid-19 tests per month.  

Covid-19 tests administered by a health care provider are not counted towards the eight OTC tests a member is provided each month.  

OTC Covid-19 tests are intended for individual use only and are prohibited from being used for employment testing (return to work testing) or test resale.  

The new coverage requirement regarding OTC Covid-19 tests in addition to legislation under the FCCRA and CARES Act will remain enacted until the HHS ends the Covid-19 public health emergency that has been active since early 2020. 

The recent rise in Covid-19 cases have been a burden on everyone. Caravus will continue to advise and advocate for our clients during this difficult (and hopefully short lived) time. Please reach out to your advisor if you need additional support.